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petitioner’s 1990-92 tax liabilities. In that same notice
respondent also rejected petitioner’s offer in compromise. On
that same date respondent sent Mark Fowler and Joylyn Souter-
Fowler (petitioners) a second Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330. In this
notice respondent sustained the filing of a Federal tax lien with
respect to petitioners’ 1994-96 tax liabilities, and respondent
again rejected petitioners’ offer in compromise.
Prior to these determinations, petitioners sought and were
offered an Appeals hearing, but they did not attend due to
personal reasons. One month after the scheduled hearing date,
the Appeals officer issued the above determinations sustaining
the filing of the Federal tax liens and rejecting petitioners’
offers in compromise. With respect to both determinations,
petitioners appealed to this Court.
The issue for consideration is whether respondent abused his
discretion by rejecting petitioners’ offers in compromise and by
sustaining the filing of the Federal tax liens.
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Last modified: May 25, 2011